Timothy Brown Against The New York City Landmarks Preservation Commission Bailey Affirmation
SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK
THE NEW YORK CITY LANDMARKS PRESERVATION COMMISSION, MICHAEL BLOOMBERG, Mayor of the City of New York, THE NEW YORK CITY DEPARTMENT OF BUILDINGS, SOHO PROPERTIES INC., JANE DOE AND JOHN DOE,
STATE OF NEW YORK COUNTY OF NEW YORK ss:
AFFIRMATION IN OPPOSITION TO PETITIONER’S CROSS-MOTION TO AMEND THE PETITION
ADAM LEITMAN BAILEY, being an attorney duly licensed to practice law in the Courts of the State of New York, affirms the following to be true under penalties of perjury: 1. I am the principal of Adam Leitman Bailey, P.C., the attorneys for named Respondent SOHO PROPERTIES INC., as well as for non-party 45 Park Place Partners LLC, (hereinafter “45 PARK” or “Building Owner”), and I make this Affirmation in opposition to the cross-motion of Petitioner to amend the Petition in all respects based upon information and belief, and based on the contents of the file I maintain in this office.
Bailey Affirmation Page 1